10 Reasons Comcast Says It Deserves Merger Approval

Battling opposition to its Time Warner takeover on everything from economics to politics.

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It’s serious for Comcast now.

On Tuesday night, the company filed a 324-page report with the Federal Communications Commission, responding to critics — often in combative tone and words, over issues ranging from economics to politics to customer service — and stating why its proposed merger with Time Warner Cable should be allowed to proceed. You can read the entire filing below. Here, in no particular order, are 10 reasons Comcast says the merger should be approved — each indented section is a quote from Comcast’s FCC filing.:

• Bigger is better:

The Transaction will greatly expand the quality of communications services available to millions of additional consumers and businesses. It will also provide the combined company with the greater scale and synergies essential to continue to invest in and upgrade its networks, innovate, and compete more effectively against the growing number of communications, media, and technology providers with national and global scale. This, in turn, will spur greater competition, investment, and innovation by other providers.

• Time Warner Cable isn’t as good as Comcast — but it will be when Comcast takes over.

Comcast has pledged to make substantial incremental investments – hundreds of millions of dollars annually – to TWC’s planned upgrades and enhancements over the next three years to accelerate improvements to TWC’s plant and facilities. Based on the information Comcast has obtained so far, it projects that the acquired customers in each market will have access to all of Comcast’s products and services within 36 months of the closing date of the Transaction, although some markets will be fully transitioned within a period as short as 12 months or even sooner.

• It’ll help poor people:

The Transaction will provide other important public interest benefits. Notably, it will extend Comcast’s acclaimed broadband adoption program,Internet Essentials, to millions of additional low-income families throughout the acquired systems. Comcast has already connected over 1.4 million low-income Americans to the Internet, far more than any other program of its kind.

• It’s good for charity:

Community and non-profit organizations and political leaders across the country confirm Comcast’s longstanding commitment to supporting local communities in a variety of important ways. These commenters include, among others, Big Brothers Big Sisters, Boys & Girls Club, United Way, Urban League chapters, By the Hand Club for Kids, City Year, and La Voz Latina. Educators from Colorado, Massachusetts, Missouri, and Hawaii also attest to the importance of Comcast’s community investment and community service initiatives, including Comcast Cares Day, the nation’s largest single-day corporate volunteer effort.

• The merger doesn’t reduce competition:

The Transaction involves no horizontal consolidation in any relevant market. After the Transaction closes, customers in the Comcast and former TWC and Charter markets at issue will have at least as many providers to choose from – for Internet, video, voice, and business services, and advertising – as they have today. No customer in any of these markets will lose a single competitive choice as a result of the Transaction.

• Because a lot of merger opponents are just trying to feather their own nests:

Comcast refused to grant various self-interested requests that were made directly to Comcast soon after the Transaction was announced – almost always with an express or at least an implicit offer to support the Transaction (or stand down, at minimum) if the requester’s demands were met. … The significance of this extortion lies in not just the sheer audacity of some of the demands, but also the fact that each of the entities making the “ask” has all but conceded that if its individual business interests are met, then it has no concern whatsoever about the state of the industry, supposed market power going forward, or harm to consumers, competitors, or new entrants. The Commission should take heed of this, because, while the Transaction is perceived as an opportunity for so many to leverage their individual interests, none has been able to make a fact-based, compelling argument that the Transaction would actually harm the public interest.

• The company isn’t trying — and won’t try — to squelch conservative voices, including Glenn Beck’s:

TheBlaze has also raised issues that have nothing to do with the Transaction, wrongly asserting that Comcast is trying to “squelch” online distribution to suppress conservative political voices.There is no merit to this claim. TheBlaze is only one of a number of conservative-leaning news channels that have recently launched or are in the process of launching.Like other MVPDs, Comcast cannot carry every conservative-leaning news channel. Nor can it carry every liberal-leaning news channel. Rather, Comcast must – and is entitled to – make editorial judgments about the programming that best meets the needs and interests of its customers.

• Comcast is already working to improve its reputation for customer service …

Comcast agrees that its customers deserve a superior customer service experience that reflects the company’s commitment to high-quality, consumer-friendly products and services. Although it has made measurable strides in this area, Comcast recognizes that it needs to improve more, and more quickly, to meet customers’ expectations. Independent from this Transaction, Comcast is investing significant time and resources to do so: as Comcast Cable President and CEO Neil Smit has made clear, improving customer service is his “top priority.”

• … and it’s particularly responding to a recent incident in which a Comcast rep wouldn’t simply end a customer’s service….

Comcast is using this incident as a “teachable moment” to reinforce how critical it is to always treat customers with the utmost respect. Comcast has created a task force to ensure that the messages it uses in communicating with its customers reinforce that the customer experience is the company’s top priority. Nearly a dozen employee coaching courses that previously were optional are now mandatory. In addition, the company is reviewing all training materials used in customer service and sales. While Comcast recognizes that it must continue to work tirelessly to enhance its customer service, the reality is that even if Comcast does a commendable job 99.9 percent of the time, there will still be some dissatisfied customers. In all events, it is not a ground on which to deny or impose conditions on this Transaction.919

• … but approving the merger certainly won’t make the customer service worse:

The record contains no evidence of customer service harms that would be caused or exacerbated by the Transaction. Instead, there are only speculative claims.Calls to deny or condition the Transaction based on customer service-related concerns, therefore, should be rejected.

Convincing? We’ll see how the FCC responds.

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